Aviva Investors - Principles for Responsible Investment

An investor initiative in partnership with UNEP Finance Initiative and the UN Global Compact 

PRI Reporting and Assessment survey 2011 

Full Responses 

Your organisation: 

Aviva Investors 

Organisational overview 

This section determines which questions in the survey are relevant to your organisation. Your organisation's characteristics also 

play a role in determining your peer group for benchmarking. Therefore, please ensure you provide accurate answers. 

You will be provided with an Other category in some questions, but please only use this option if the alternatives listed do not 

represent you in any way, as this may prevent you from having results comparable with peers. 

You will not be able to continue the online survey until you have completed fully both this section and the 

'Governance, policy and strategy' section. However, you can prepare your answers for the following sections by reviewing the 

full list of questions and explanatory notes on the PRI extranet. 

This section may require you to collect information from multiple sources. We strongly recommend you begin collecting this 

information as soon as possible and before commencing the survey. 

This section of the survey is not scored. 

Q 2 What category best describes your organisation 

Please select one category 

which best represents your 

primary activity. 

Investment managers (IMs) 

Primarily invest directly in companies and other asset classes, not via third party funds 

Q 4 As an investment manager, which category best describes the products and services your 

organisation provide(s) 

Please select one: 

Mainstream investment manager 

Q 5 Which client category represents the highest proportion of your assets under management 


Institutional investors 

Q 6 Please indicate the number of staff your organisation employs and select the level of complexity that 

best describes your organisation 

Approximate number of staff: 1386 

Level of complexity of organisation: 

Highly complex 

Copyright ©2011 PRI Association. All rights reserved. page 1 / 30

Q 7 What were your organisation's total assets under management as of 31 December 2010, including the 

assets of all your consolidated subsidiaries 

billions millions thousands units 

Total AUM: 259 787 000 000 

Currency: 

U.K. Pound Sterling (GBP) 

Date of assets under management figure 

year month day 

Date: 2010 December 31 

The amount you indicated above is roughly equal to the amount calculated below in United States Dollars. Please 

confirm that this figure is approximately correct before proceeding. Exchange rates are from the International 

Monetary Fund. 

Source: IMF Exchange Rate archive, December 2010 

billions millions thousands units 

Total AUM in USD: 400 979 973 753 

Q 8 Please provide an approximation of your average asset mix for 2010 or your most recent count, in %. 

(For asset classes you hold in insignificant amounts you may choose not to list them and will not be asked 

related questions. +/ 5% is sufficient; the sum of all the fields must be 100 %) 

Asset class 

Internal 

active 

Internal 

passive 

External 

active 

External 

passive 

Listed equity (developed markets) 16 % 4 % % % 

Listed equity (emerging markets) 1 % 0 % % % 

Fixed income sovereign and 

other noncorporate issuers 

21 % 5 % % % 

Fixed income corporate issuers 26 % 6 % % % 

Private equity 0 % 0 % % % 

Listed real estate or property 1 % 0 % % % 

Nonlisted real estate or property 8 % 0 % % % 

Hedge funds 0 % 0 % % % 

Commodities 0 % 0 % % % 

Infrastructure 0 % 0 % % % 

Cash 7 % 0 % % % 

Other please specify: 

Mixed units, derivatives, 

other 

5 % 0 % % % 

Please contact the PRI Secretariat at assessment@unpri.org before indicating that more than 10% of your assets fall into the 

'Other' category. A response of 'Other' may render the benchmarking results less useful for you and your peers. 

If you manage balanced or multiasset class products with listed equity, fixed income and potentially other asset classes, the 

relative assets in these funds need to be separated out into the different asset classes. 

Total (must add up to 100%): 100 % 


Q 9 Please provide the following information based on your asset classes holdings: 

(rough estimates of /+ 5% are fine; when negligible, please leave as zero) 

B. What percentage of your assets invested in publicly listed 

companies are invested in companies where your 

organisation or external investment managers have 

significant control Significant control implies that active 

ownership can influence change more so than proxy voting 

and engagement alone. 

0 % 


Governance, policy and strategy 

This section is focused on the governance, policies and strategies guiding your organisation's approach to responsible investment 

(RI). 'Policy' in this section may refer to one overall RI policy or multiple policies that address various elements of RI or ESG 

issues. Some questions in this section are scored, while other questions are not scored but do determine the applicability of 

subsequent questions. 

Please make sure you provide accurate answers. You will not be able to enter this section unless you have completed the 

"Organisational overview" section. You will not be able to continue the survey until you have finalised this section. 

However, if you wish to begin preparing your answers for the following sections, you may do so by reviewing the full list of 

questions and explanatory notes in the manual provided on the PRI extranet. This section will be scored separately from the six 

Principles. 

Q 11 Please provide a description of how your governance, policies and strategies address RI and ESG 

issues. 

Note that this text in addition to being part of the full survey will also be part of the Executive Summary 

of the survey. The Executive Summary is a separate document that will collate the text you provide for 

each of the introductory sections of the survey (GPS and the six Principles). 

As a founding signatory to the UN Principles for Responsible Investment (PRI), Aviva Investors has demonstrated its dedication 

to the worldwide implementation of environmental, social and corporate governance (ESG) principles. We have a dedicated SRI 

team, which provides awardwinning SRI investment expertise for our clients with SRI objectives. We also have a dedicated 

corporate governance team. There are 20 investment professionals in these teams, and the analysis of each of the teams is 

shared internally. 

In order to deliver the PRI within the entire Aviva Group, we have developed the following general approach to how we govern, 

manage and operationalise the principles: 

1. Governance 

There is an Aviva Investors Executive Committee member responsible for Corporate Responsibility (CR) which includes 

responsibility for the application of the PRI. The Board of Aviva Investors and the Board of Aviva PLC use the results of this PRI 

assessment to help govern our delivery of responsible investment in general, as well as our adherence to the principles within 

the PRI in particular. These formal annual Board reviews are held in the fourth quarter. The Aviva Investors' Heads of 

Sustainability and Governance attend the full Board to present progress and future plans in addition to the Executive Committee 

member responsible for CR. 

2. Policy 

The PRI itself is part of the policy framework of Aviva Investors. Our membership of the PRI is captured within the Aviva Group 

CR framework. Policy implementation reports are provided to the Group CR Committee and reviewed at the Aviva Investors CR 

Committee. Aviva Investors also publishes its own approach to ESG voting and integration within our public policy 

documentation. An SRI advisory committee, comprised of leading professionals in the area of sustainability, provide advice and 

guidance on the implementation of our policy. 

3. Strategies 

Aviva believes that ESG factors have a material impact on the ability of many companies to generate longterm earnings. 

Consequently, we have developed a clear strategy for integration and engagement. 

Regarding integration, as the majority of a company's value is derived from its ability to generate longterm earnings, we believe 

that identifying and integrating ESG factors into valuation analysis is crucial. As part of our investment process we identify and 

integrate factors which impact longterm earnings, such as ESG issues, into our valuation analysis. Our research suggests that 

the way in which companies manage the extrafinancial aspects of their business provides a useful proxy to management 

quality and business sustainability, and has a material impact on shareholder value. Analysing ESG issues can therefore help 

us to differentiate between winners and losers from a range of ESG themes. 

Regarding engagement, the key ESG risks and opportunities identified within our investment analysis form the basis of our 

future engagement plans with specific companies. Where material issues within our holdings are identified, then a structured 

programme of engagement ensues. This dialogue is generally included within our routine company management meetings. 

Where companies are intransigent on material issues then we may escalate our engagement to include voting action at AGMs, 

divestment and/or selective public expressions of concern. We will lead or join a collaborative engagement initiative where we 

believe this will have a significant impact and generally support this with additional individual engagement. 


Q 12 Do you have a policy or a set of policies that make specific reference to responsible investment, and 

if so, do they cover environmental, social, and governance issues 

Please select "Yes" or "No": 

If "Yes", which issue(s) does it cover 

Yes 

Environmental 

Social 

Governance 

Q 13 For the following asset classes, to what extent has your policy or approach to responsible investment 

been incorporated into internal management processes (e.g. business planning, strategic planning, or 

similar) 

Extent that your approach has been 

incorporated into internal 

management processes 

Asset class 

Listed equity (developed markets) 

Listed equity (emerging markets) 

Fixed income sovereign and other noncorporate 

issuers 

Fixed income corporate issuers 

Listed real estate or property 

Nonlisted real estate or property 

Please select: 

"Large", "Moderate", "Small" or "Not at all" 

Large 

Moderate 

Moderate 

Moderate 

Large 

Large 

Q 14 Within your organisation: 

What roles are present 

Who has a clear responsibility related to responsible investment implementation and 

Are there incentives and/or training on RI/ESG issues 

Roles present in 

your organisation 

Responsibilities 

on RI/ESG 

Please check all that apply 

Incentives 

Training 

Please choose among 

"Yes, for all", "Yes, for some" or "No" 

Board of trustees or board of 

directors and their 

committees 

Yes Yes N/A Yes, for some 

Chief Executive Officer or 

Chief Investment Officer or 

equivalent 

Yes 

Yes 

No 

Yes, for some 

Other senior management Yes Yes 

No 


Portfolio managers Yes Yes Yes, for some Yes, for some 

Analysts Yes Yes Yes, for some Yes, for some 

Researchers Yes Yes Yes, for some Yes, for some 

RI or ESG specialist Yes Yes Yes, for all Yes, for all 


Advisory Committee 

Yes 

Yes 

No 

Yes, for all 


Q 15 Select any of the following RI, ESG and/or SRI approaches that you or your external investment 

managers currently apply in the investment decision making process. 

Please note that this question helps determine which questions you will be asked in subsequent sections, 

so please carefully review the definition of each possible answer. 

Please select all those that are relevant 

(columns are visible based on your answer 

to Q8 on asset classes breakdown) 

Internally managed 

Externally managed 

Exclusion based on ethical criteria 

Screening as a way to avoid the potential 

negative publicity surrounding the 

companies/sectors in question as it may 

adversely reflect on you or your manager's 

brand/license to operate 

Screening based on a belief that exclusion 

or inclusion of certain investments from 

your investment universe can have a 

material effect on portfolio performance 

ESG analysis within individual investment 

decisions, possibly including these factors 

into valuation and investment performance 

models 

Themed investing 

None of the above (this reply excludes any 

of the above) 

Q 16 Please indicate which of the following thematic investment strategies your organisation employs 

Cleantech 

Please select all that apply 

Microfinance 

Sustainable forestry 

Global health 

Water 

Other (1) please specify: 

Climate Change 


Sustainable Consumption 


Quality of Life 




Q 17 Please select any of the following active ownership activities that you, your external service 

providers or your external investment managers have undertaken in 2010 on behalf of your organisation 

Please note that this question helps determine which questions you will be asked in subsequent sections, 

so please carefully review the definition of each possible answer. 

(Proxy) voting related to listed equity investments in 

the following asset classes: Listed equity 

(developed markets), listed equity (emerging 

markets), or listed real estate/property (including 

the votes on listed securities held in hedge funds). 

File and/or cofile shareholder resolutions on listed 

companies. 

Engagement on ESG issues with listed equity or 

fixed income issuers in the following asset classes: 

listed equity (developed markets), listed equity 

(emerging markets), listed real estate/property, 

listed securities held in hedge funds, or fixed 

income corporate issuers. 

Ownership and engagement activities focused on 

ESG issues related to investments in the following 

asset classes: Listed equities which permit a 

significant control, sovereign and other noncorporate 

fixed income, private equity, non listed 

real estate/property, hedge funds, infrastructure, or 

other. 

None of the above (this reply excludes any of the 

above). 

You may select any approach you or your 

external managers, service providers or 

partner entities adopt on your behalf 

Q 18 Please add any overall comments and clarifications related to governance, policy and strategy here. 

The Corporate Governance and Corporate Responsibility Voting Policy is itself carefully governed within Aviva Investors. There is 

an annual governance cycle of policy review; board discussion and approval of the new policy (including oversight at both the 

Aviva Investors and Aviva Board plc levels); engagement planning; recording and review. The effectiveness of this engagement 

work is reviewed as part of the subsequent year's policy update. 


Principle 1 We will incorporate ESG issues into investment analysis and decisionmaking processes. 

This section focuses on the integration of ESG considerations into the investment process. The questions are split into three 

sections. Only questions relevant to your organisation will be displayed, based on your responses to Q 8 (your investment 

management structure and asset class breakdown). 

The three sections are: 

I. Internally and actively managed investments; 

II. 

III. 

Externally and actively managed investments; and 

Passively (both internally and externally) managed investments. 

Some questions in this section are scored. Any question that is scored, but is not relevant to your organisation, based on your 

investment management structure and asset class breakdown or other responses, will not affect your overall score for Principle 1. 

You do not need to complete Principle 1 questions before completing questions for other Principles. While completing this section 

you are free to navigate to any of the other sections of the survey without losing answers already completed. 

Definitions 

Please note that this section of the survey focuses on investment decisionmaking processes and how ESG issues are integrated 

in these processes. It does not address the integration of ESG issues in other parts of your organisation and/or activities, such as 

the running of offices (e.g. how you manage your own organisation's waste) or your organisation's collaboration with other 

investors on ESG issues. 

ESG Integration, as addressed in this section of the survey, relates to the consideration of ESG issues alongside 

traditional financial measures, based on the belief that ESG issues can affect the performance (risk and/or return) of 

investment portfolios (to varying degrees across companies, sectors, regions, and asset classes and through time). 

Integration is considered to be: 

screening based on the belief that exclusion or inclusion of certain investments in the investable universe can effect materially 

on the portfolio's financial performance; and/or 

ESG analysis within individual investment decisions based on the belief that such analysis can effect materially on the 

investment's financial performance. 

Please note the view that ESG issues can influence investment returns based either on: 

1. The premise that performance on these issues will eventually be reflected in financial and operational outcomes and that 

externalised costs in the future will be priced and have an impact on revenue growth, margins, etc.; or, 

2. The premise that the way in which the market rates or prices the stock will be affected even in the absence of an impact on 

financial or operational performance. 

Exclusion of stocks or sectors from portfolios or downweighting them based on the possibility that an association with the stocks 

may adversely affect the owners profile or brand amongst stakeholders is not regarded as integration. Also, exclusion based on 

ethical considerations of sectors is not considered ESG integration. However, screening based on norms that are believed to be 

material in the investment process are included in the above definition of integration. 


Q 19 Please provide a description of your organisation's approach to this Principle. For example, how do 

your organisation's investment analysis and decisionmaking processes incorporate ESG issues 

If your assets are managed both internally and externally, please describe how you address this in both 

portions of your assets. In addition, please describe any activities you may be doing to integrate ESG 

issues into the management of those investments that passively track indices (if you use this approach). 




Environmental, Social and Corporate Governance (ESG) issues are integrated into our investment process. Analysts and fund 

managers are expected to consider ESG risks and opportunities when forming investment views. 

Practical steps we have taken include: (1) a material proportion of our commission is used to support ESG research, (2) the 

head of the Sustainable and Responsible Investments (SRI) team regularly chairs our front office investment meeting. SRI and 

corporate governance colleagues routinely attend, (3) The research of the Corporate Governance and SRI teams is shared 

internally, and (4) Our training course for colleagues, run in partnership with City University's Cass Business School, includes a 

module on ESG. 

In addition, during 2010 our chief investment officer (CIO) engaged directly with the managing directors of our key sellside 

brokers to highlight the importance that we place on ESG issues as an integral part of investment research. 

Q 20 What percentage, by asset class, of your organisation's assets under active management internally 

integrate the consideration of RI/ESG issues in investment decision making processes such as 

researching ESG information and/or constructing/managing portfolios and to what extent 

Please note that the percentages requested here are different from the data in Q8. 

Asset class 

What percentage of 

assets under active 

management 

internally (see 

example in notes) 

(+/ 5 per cent is 

sufficient) 

Research 

(gathering and 

analysing) 

Portfolio 

construction and 

management 

If percentage is greater than zero, 

please select: "Large", "Moderate", 

"Small" or "Not at all" 



Fixed income sovereign and other 

noncorporate issuers 

Large Moderate 

100 % 

Large 

Large 

100 % 

60 % Moderate Moderate 


100 % 

Moderate 

Moderate 


100 % 

Large 

Moderate 


100 % 

Large 

Moderate 


Q 21 For the assets under active management internally that integrate the consideration of RI/ESG issues, 

to what extent do you have a process for monitoring the capability of investment analysts, portfolio 

managers and other relevant investment professionals on how they integrate the consideration of RI/ESG 

issues into investment analysis and decisionmaking processes 

Applies only to investments that include integration of RI/ESG issues as indicated in Q20. 

Monitoring 

Asset class 




issuers 






Moderate 

Small 

Small 

Moderate 

Moderate 

Moderate 

Q 24 Has your organisation directly, or via a mandate with an external manager, requested that any 

passive index tracking investments be managed relative to indexes that are constructed using relevant 

ESG issues 

Please select: "Yes" or "No" 


No 

Please add any other comments regarding how you are, or are not, addressing ESG issues in your passively managed 

investments. 

Q 25 Please add any overall comments and clarifications related to Principle 1 here. Please also describe 

any significant activities relating to Principle 1 not already captured by your answers above. 

The greatest problem we face when assessing our own compliance with Principle 1 is the circularity within the definition. In 

other words, no fund manager will ignore material environmental, social or corporate governance issues precisely because they 

are material. The question may be better phrased as "To what extent do you try to use ESG analysis to exploit market 

inefficiencies..." in the various asset classes. 


Principle 2 We will be active owners and incorporate ESG issues into our ownership policies and 

practices. 

This section is focused on active ownership and is divided into three parts. You will see only those questions relevant to your 

organisation. 

The first part addresses voting related to listed investments. The second part addresses nonvoting engagement activities 

undertaken by your organisation or on your behalf by third parties with listed equity and corporate fixed income issuers. For the 

purpose of this survey, the term 'engagement' refers to nonvoting contact with companies to discuss concerns regarding ESG 

issues. The third part addresses ownership and engagement practices for other asset classes such as sovereign and other noncorporate 

fixed income issuers, private equity, nonlisted real estate/property, hedge funds, and infrastructure. This third section 

also covers any listed equities where investors have significant control (as defined in Q9, explanatory note [B]). 

The third section is necessary to account for the differing levels of influence that investors may acquire when investing in other 

asset classes versus those of listed equities. 

The contents and parts for this section of the survey are therefore: 

1. Voting and engagement activities related to listed equity investments undertaken by: 

A. internal staff; 

B. external parties (e.g., service providers and external managers). 

2. Engagement activities related to corporate fixed income issuers; 

3. Ownership and engagement activities for sovereign and other noncorporate fixed income, private equity, nonlisted real 

estate and property, hedge funds, and infrastructure, as well as listed equities when they represent significant control. 

While completing this section you are free to move to any of the other sections of the survey without losing work already done. 

Please note that for this survey, proxy voting activities entail any casting of votes at AGMs and the filing or cofiling of resolutions. 

Engagement activities refer to all interactions with investee companies that are not related to voting activities. Engagement 

activities should seek to achieve relevant information and promote better ESG performance by companies. Such activities involve 

usually written communications, phone calls and meetings with management. For indirect investors in certain asset classes, 

such as private equity, infrastructure, and nonlisted real estate, active ownership may not be possible with the underlying asset. 

Active ownership in this case should be viewed as engaging with third party managers to consider and interact on ESG issues 

with underlying holdings. Working with governments to modify laws, rules and regulations in favour of ESG issues should not be 

counted as engagement in this part of the survey and it will be addressed separately in Principle 4 and 5. 


Q 26 Please provide a description of your organisation's approach to this Principle. For example, how is 

your organisation an active owner and how does it incorporate ESG issues in its ownership policies and 

practices 

Describe both your voting activities and any other engagement activities you undertake across the 

different asset classes you hold. 




We believe that companies that are well governed and operate in a responsible and sustainable way, will be better able to 

create longterm shareholder value. Consequently, we are active owners on behalf of clients, and have incorporated 

environmental, social and corporate governance issues across the breadth of our ownership policy and practices. 

In 2010, Aviva Investors published its policy on stewardship and in particular how our policy and procedures meet the 

requirements of the UK Stewardship Code. We have supported the development of good governance in the UK and beyond for 

many years and we very much hope that the Stewardship Code achieves its purpose of 

enhancing the quality of engagement between institutional investors and companies to help improve long term returns to 

shareholders and the effective exercise of governance responsibilities. 

Our core focus on promoting high standards of corporate governance is complemented by the inclusion of a range of corporate 

responsibility issues when voting at AGMs. For example, the policy highlights: (i) the inclusion of appropriate information on 

material corporate responsibility issues within enhanced business reviews; (ii) the ability of remuneration committees to 

consider corporate responsibility performance when setting the remuneration of executive directors; and, (iii) the importance that 

we place on the board's role in setting a company's values and standards. 

Q 27 Do you have a (proxy) voting policy, and, if so, does it address environmental, social and governance 

(ESG) issues 

Do you have a voting policy 

If Yes, please select all that apply: 

Yes 

Environmental 

Social 

Governance 

Q 28 For listed equities, please indicate the ratio of (proxy) votes cast, either directly or via third parties 

(such as an external service providers or external investment manager), against those you could have 

cast in 2010 for at least one of the following measures: 

by ballots item or resolution; 

by meetings (e.g. AGMs, EGMs, special); 

by listed assets under management. 

Please answer for at least one of these measures, 

if available please provide others as well 

Ballot items Meetings Listed assets 

We do not track our 

listed equity voting 

activities 

Actually cast vs. all you 

could have cast 

% 62 % 85 % 


Q 29 For listed equities, who makes voting decisions on behalf of your (or your client's) organisation 

Please rank the importance of the different groups listed below based on the proportion of decisions 

made by that group. 

Please note that subsequent questions will be asked specifically on the group that you list as most 

important and if specified of the second and third most important. Only the activities of the most 

important will be scored. 

Most important: 

Second most important: 

Third most important: 

Please select from: 

"Internal investment manager or other internal staff" 

"Internal voting or governance group" 

"External investment manager" 

"External proxy voting service" 

"External service provider" or 

"Other third party voting support entity" 

Internal voting or governance group 

Internal investment manager or other internal staff 

External proxy voting service 

Q 30 For those listed equity votes you cast: 

a. to what extent is information related to voting items gathered and analysed before voting decisions 

are made; and 

b. do you monitor whether voting is done in accordance with your voting instructions 

a. Information gathered and analysed b. Monitor voting 

Please select 


Large 

Please select 

"Yes, for all", "Yes, for some" or 

"No, we make no effort to ensure" 


Q 31 Do you proactively inform your listed equity companies of your rationale when you abstain or vote 

against management recommendations 



If "Yes", please indicate how this disclosure is communicated to companies. 

If answering "No", please explain why. 

The nature of a voting issue and the size of our holding determines whether we engage with a company in advance of a vote or 

afterwards. Communication can take the following forms: 

1) Telephone conversations or emails in general this will be with the Company Secretary. We believe this is the most effective 

way to ensure companies have the opportunity to respond ahead of voting deadlines, which also ensures that if their 

explanations or assurances are sufficient, we can still change our voting stance. 

2) Letters in general these will be addressed the Chairman and Company Secretary 

3) Meetings these will be with board directors and senior management 

4) Attendence at company AGMs 

Companies can also view our voting record, which we disclose three months in arrears, on the Aviva Investors website 

(www.avivainvestors.com/corporategovernance). 

Q 32 For the listed equities that you manage, do you provide (proxy) voting services for your clients if they 

request them 


Yes, according to our own policy as well as clientspecific policies 


Q 33 For listed equity votes that your external manager or service provider casts on your behalf, to what 

extent did you monitor that voting decisions were analysed and made in accordance with your (proxy) 

voting policy 

Please select 



Large 

Q 34 How does your listed equity securities lending programme address voting 


We recall some securities for voting on some ballot items on an adhoc basis 

Q 35 To what extent do you and/or your agents review shareholder resolutions put forward by other 

shareholders to determine whether or not to support the resolution 

Please select 

"Large", "Moderate", "Small", "Not at all" or 

"We do not vote on shareholder resolutions" 

Voting managed internally 

Voting managed externally 

Moderate 

Moderate 

Q 36 How many shareholder resolutions related to ESG issues did you file or cofile during 2010 and, of 

these, what percentage were: 

voted on by shareholders 

withdrawn due to changes at and/or negotiations with the company 

withdrawn with no changes at the company in 2010 

As Lead filer 

As Cofiler 

Number of ESG shareholder resolutions filed 0 1 

Of these: 

Of these led 

shareholder 

resolutions 

Of these cofiled 

shareholder 

resolutions 

Voted on % 0 % 

Withdrawn due to changes at and/or negotiations 

with the company 

% 0 % 

Withdrawn for other reasons, please specify: 

The Company rejected our proposals 

on technical grounds. We decided not 

to pursue this issue via the French 

courts. 

% 

100 % 

Total percentage (must be 100%) 0 % 

100 % 

Please explain why you filed or cofiled any shareholder resolutions related to RI/ESG issues during 2010. 

Our reason for filing was to seek a resolution to split the roles of CEO and chairman, (both performed by Frederic Oudea) at its 

May 2010 AGM, as we were concerned over the concentration of power at the top of the company and the lack of sufficient 

checks and balances. 

The Company rejected our proposals on technical grounds. Despite the issued share capital threshold being met (to file a 

resolution), the Company said it was unable to accept the proposal as its bylaws did not allow shareholders to have a say on 

the roles of CEO and chairman. We decided not to pursue this issue via the French courts. 


Q 37 Do you have a written engagement policy or other documents that direct engagement with listed 

equity and fixed income issuers; if so, do these policies address environmental, social and governance 

(ESG) issues 

Engagement policy or 

other documents 

Do they address E, S or G 

Asset class Please select "Yes" or "No" Please select all that apply 

Listed equities Yes Environmental 

Social 

Governance 

Fixed income corporate issuers Yes Environmental 

Social 

Governance 

Q 38 Who engages with listed equity or fixed income issuers on behalf of your (or your client's) 

organisation Please rank the importance of the different groups listed below based on the engagements 

undertaken by that group. 

Please note that subsequent questions will be asked specifically on the groups that you list here. Only the 

activities of the most important will be scored (except for question 39 where all will be scored). 

Most important: 

Please select from: 

"Internal staff" 

"External engagement service provider(s)" 

"External investment manager(s) " 

"Other external entity" 

Internal staff 

Second most important: 

Third most important: 

Fourth most important: 

If "Other external entity" is selected, please list it here. 

Q 39 In total, how many listed equity and fixed income issuers did your organisation engage with or were 

engaged with on your organisation's behalf on ESG issues in 2010, by level of engagement 

Please do not double count. Engagements that are listed in one column should not 

be repeated in another. Choose to list them where the highest level of effort is 

being applied. Consider both individual and collaborative engagements carried out 

during the year. 


Extensive engagement 186 

Moderate engagement 50 

Basic engagement 888 

We do not track these 

engagement activities 

External 

enagement 

service 

provider(s) 

External 

investment 

manager(s) 

Other 

external entity 


Q 40 Approximately what proportion of the engagements with listed equity or fixed income issuers 

undertaken by your organisation or on your organisation's behalf addressed environmental, social or 

governance (ESG) issues 

(+/ 5% rounding is sufficient) 


External 

enagement 

service 

provider(s) 

External 

investment 

manager(s) 

Other 


Environmental 15 % % % % 

Social 15 % % % % 

Governance 70 % % % % 

We do not track these 

engagement activities 

Q 41 To what extent do you assess and monitor the ESG engagement competency and capabilities of the 

following groups 




Large 

Q 42 Given your (or your client's) engagement policy and/or approach to engagement, to what extent do 

you or do the third parties acting on your behalf, have a process for identifying and prioritising ESG 

related engagement opportunities 




Large 

Q 43 To what extent do you or your third party engagement providers or investment managers set ESG 

engagement objectives and evaluate engagement successes 




Large 

Q 44 To what extent do you or your external investment manager integrate the information gained from 

ESG engagements into the investment decisionmaking process 




Large 


Q 46 What percentage of engagements with listed equity and fixed income issuers that ended in 2010 were 

deemed successful 


External 

enagement 

service 

provider(s) 

External 

investment 

manager(s) 

Other 


Engagement success 41 % % % % 

What measures does your organisation or its external service provider(s) and or external manager use to assess the 

impact and success of engagement with listed equity and fixed income issuers, and how did you perform in 2010 

based on those measures 

This is calculated only for extensive engagement arising from our corporate responsibility voting, high priority engagement 

targets, CDP and UN Global Compact engagement programmes. Out of a total target sample of 234, 96 demonstrated change. 

Two examples are given below to highlight the way in which we measure the effectiveness of our engagement work. 

1. Carbon Disclosure Project (CDP) 

Over the last four years, the Aviva Investors' Sustainable and Responsible Investment (SRI) team has undertaken focused 

engagement to encourage companies with a high climate impact to disclose their emissions via the Carbon Disclosure Project. 

In 2007, the team engaged with 29 persistently nonresponding companies where we felt that climate change was potentially a 

material issue requiring Carbon Disclosure Project disclosure. Subsequent portfolio reviews expanded the scope of our 

engagement to 39 companies. 

In terms of the overall effectiveness of this project, four years on, 33 out of those original companies (85%) have provided a 

response to the Carbon Disclosure Project for at least one of the years that the engagement programme has run. 

We still have concerns about the overall quality of Carbon Disclosure Project responses: for example, missing performance 

data, inconsistency (some companies have responded in some years and not others), and a number of the companies who 

have responded have chosen not to make their response publicly available. 

We will continue to engage with persistent nonresponders, and have indicated that we may withhold support from the report 

and accounts at future AGMs, should nonresponding companies continue to drag their heels. 

We have also participated in a collaborative engagement through the UN PRI to write to more than 30 companies to encourage 

disclosure of scope 1 and 2 greenhouse gas emissions, together with details of targets and emissions reduction programmes. 

In 2009, Aviva Chairman, Lord Sharman, called for the CDP to go beyond disclosure and challenge companies to take action 

that mitigates their climate change emissions. In 2010, Aviva provided seed funding and Aviva Investors provided expert input via 

an investor steering group to develop a Carbon Mitigation Project, later renamed Carbon Action. This was launched in 2011. 

2. Vedanta Resources 

Aviva Investors conducted a major engagement exercise at Vedanta's July AGM because we had profound concerns about their 

poor CR conduct. The company had not responded to previous requests for a meeting on the subject and, consequently, we 

attended its AGM to put our concerns on public record. 

Vedanta has come under international scrutiny for its plans for a bauxite mine and the associated expansion of its Lanjigarh 

alumina refinery. Aviva Investors shared this concern on a number of grounds, including financial, human rights in relation to 

indigenous communities and environmental and biodiversity risks. 

Commissioned by Aviva Investors, a report by global ESG research providers EIRIS made a series of recommendations to the 

Vedanta board regarding the actions needed to reform the way that it governs CR risks and opportunities. 

Aviva Investors attended the company's AGM in July 2010 and presented the report and its associated recommendations to the 

board. We asked them to respond, which they committed to do. 

Subsequently, we met with Vedanta in November 2010 to discuss the actions recommended by EIRIS. While positive actions 

had been taken by the company including progress on a number of the recommendations, we believe that progress still needs 

to be made before Vedanta's procedures can be considered to be adequate and will continue to build on the success to date. 


Q 47 Do you have an active ownership policy and/or strategy that addresses environmental, social and 

governance (ESG) issues for each of the following asset classes 

Asset class 


issuers 

Nonlisted real estate and property 

Policy and/or strategies address 

Environmental 

Social 

Governance 

Environmental 

Social 

Governance 

Q 48 Per asset class, which role is most important in bringing forth active ownership activities on your 

behalf and, to what extent are ESG issues addressed by this role in these ownership activities 

Asset class 

Fixed income 

sovereign and other 

noncorporate issuers 

Nonlisted real 

estate/property 

Select the most important: 

"Internal staff", "External engagement service 

provider(s)", "External investment manager(s)", 

"Other external entity" or "Nobody" 



Please select the extent of 

active ownership activities: 

"Large", "Moderate" or "Small" 

for each of the categories selected 

Small 

Large 

Q 49 To what extent do you assess and monitor ESG active ownership competency and capabilities 

undertaken by the groups listed below in the following asset classes: Listed equities with significant 

control, fixed income, sovereign and other noncorporate issuers, private equity, nonlisted real 

estate/property, hedge funds and infrastructure 


"Large", "Moderate", "Small", "Not at all" or "Not applicable 


External engagement service provider(s) 

External investment manager(s) 

Other external entity 

Large 

Not applicable 




Q 50 Please describe your organisation's , your external service providers or your external investment 

manager's approach to addressing ESG issues in active ownership in the following asset classes. Please 

include a description of the processes used to ensure ESG issues are addressed, any metrics used to 

gauge success, the sources of your expertise and specific examples. 

Asset class 

Fixed income sovereign 

and other noncorporate 

issuers 

Nonlisted real estate and 

property 

Please add your remarks 

Our approach to engagement in this area continues to evolve insofar as we are experimenting with 

the Emerging Market Sovereign Debt team's engagement with countries in their benchmark. We are 

yet to be convinced that the engagement is effective, but we believe there is an opportunity to raise 

questions as we regularly meet EM ministerial representatives in our research trips. We expect 

attribution of any change to be a challenge at best. Other noncorporate issuers such as 

Development Banks and quasi government bodies are not in scope of this initiative. 

With regards to direct real estate new acquisitions, we ensure we have considered their energy 

performance certificates and also have an internal policy to conduct an environmental survey looking 

into the historic uses and potential land contamination of the assets. In this way we can forecast 

potential capital outlays and mitigate unnecessary or unexpected capital costs that would reduce 

the assets financial return. All qualifying acquisitions are presented to the investment transaction 

committee where the expected performance of an asset is analysed, part of this is to consider 

potential future risks and opportunities related to corporate responsibility for the particular 

investment. 

We have introduced an Environmental Management System (EMS) that aims to formalise our 

environmental reporting procedures and highlight areas for improvement within our entire direct 

portfolio. We believe this will be of great benefit to all our funds and can benefit clients directly. 

Environmental issues are fully incorporated in our investment and acquisition process. On our 

existing portfolio we are gathering and analysing ESG information through our EMS and 

Sustainability Charter. This primarily includes information on: 

1. Occupier engagement 

2. Energy management 

3. Water management 

4. Waste management 

5. EPC regulations 

6. Staff training 

7. Management of alterations 

8. Transport 

9. Community engagement 

When looking at new funds to invest in we have encouraged alignment of interest between the fund 

manager and investor for example on a recent fund we invested in there was both manager and 

company coinvestment, and a suitable fee structure including an additional performance fee hurdle 

we proposed. There are many examples of buildings that have reached high BREEAM (BRE 

Environmental Assessment Method) environmental standards that have been developed, refurbished 

or purchased within the real estate portfolios that we manage and it is an aspiration for all our 

properties when possible. 



We remain concerned that the structure of this questionnaire may inadvertently promote the outsourcing of engagement in 

preference to its integration within investment managers. This is counter to the foundations of the PRI in general, and Principle 1 

in particular. While we acknowledge a role for outsourced engagement, we believe that enabling investment managers to ignore 

these issues by outsourcing them to a third party will reduce the effective oversight of ESG practices. This is because company 

Board members are most interested in responding to the concerns of those making investment decisions. Asset owners should 

be encouraged to hold asset managers to account for their ESG engagement not to outsource it. 

Qu 28 the percentage of meetings is accurately calculated; the percentage of listed assets is a conservative estimate based 

on the fact that we focus on our largest cap holdings which constitute a disproportionately high percentage of the overall market 

value (for example, analysis of the FTSE All Share shows that the top 100 companies comprise 85% of the total market cap). 

Qu 46 We have calculated this on the basis of the proportion of 'extensive' engagement we consider to have been successful, 

the success of our UN Global Compact and CDP engagement programmes and where we have been able to improve our voting 

position based on improvements in corporate responsibility disclosure. 


Principle 3 We will seek appropriate disclosure on ESG issues by the entities in which we invest. 

Principle 3 is about ensuring that information related to ESG issues is disclosed by companies and other entities in your 

organisation's investment universe. It is closely related to your activities on Principle 1 and Principle 2. 

This section lists questions regarding: 

Who seeks ESG disclosure information for your organisation; 

The level of detail and content that is sought; 

The information you may be seeking regarding norms, standards, codes of conduct or international initiatives related to RI/ESG. 

While completing this section you are free to move to other sections of the survey without losing work you have already done. 

Q 52 Please provide a description of your organisation's approach to this Principle. For example, how 

does your organisation seek appropriate disclosure on ESG issues by the entities in which it invests 

Note that this text in addition to being part of the full survey will also be part of the survey's Executive 

Summary. The Executive Summary is a separate document that will collate the text you provide for each 

of the introductory sections of the survey (GPS and the six Principles). 

We actively promote greater corporate accountability on environmental, social and goverance (ESG) issues via enhanced 

disclosure across a broad range of our assets and at face to face meetings. 

One distinctive element of our approach is our corporate responsibility disclosure voting. It has been Aviva Investors policy since 

2001 to promote increased Corporate Responsibility (CR) reporting via AGM voting. In 2010, this policy was applied to all FTSE 

350 Index and EuroFirst 300 Index companies, in addition to selected client portfolios, (a subset of our full governance voting 

policy). In 2011, this will be extended to the MSCI World Index. The policy states that we expect these companies to disclose 

information on their exposure to and management of key environmental and social risks. Where companies publish insufficient 

information, we may abstain or vote against the resolution to adopt the Report and Accounts. As far as we are aware, we were 

the first institutional investor in the world to adopt such a policy, and it remains a particularly distinctive element of our overall RI 

strategy. 

In 2010 Aviva plc introduced a separate advisory vote for the Group CR report. Aviva was the first company in the UK and the 

first financial institution in the world to take this step. We actively encourage other companies to take their own step in this 

direction, which we believe will contribute to creating the right kind of discussions within the boardrooms of listed companies 

around the world, and then between the company and its shareholders. We advocate this in one to one meetings with 

companies and through our work on the Sustainable Stock Exchanges initiative. 

Q 53 Who asked for and/or collected from your organisation's investee companies (or other investment 

entities) information about their ESG policies, practices or performance in 2010 



External investment manager(s) 

External engagement service provider(s) 

External research providers 

Brokers / dealers 


None of the above: Investee companies, or other investment entities, were 

not asked to provide information about their ESG policies, practices or 

performance in 2010 (please specify below why not) 

If investee companies were not asked, please specify why. 


Q 54 To what extent did you or your external agent(s) seek appropriate disclosure on ESG issues by the 

investees and, where necessary, encourage investee companies to produce standardised and/or 

systematic reporting about their ESG policies, practices or performance in 2010 

Asset class 




issuers 






Large 

Small 

Not at all 

Moderate 

Large 

Large 

Q 55 In which format or mechanism have you or your third party agents requested reporting on ESG 

policies, practices or performance 

Reporting formats 


Integrated with regular financial reports 

Standalone corporate (social) responsibility or sustainability reports 

Global Reporting Initiative (GRI) 

Carbon Disclosure Project (CDP) 

Global Framework for Climate Risk Disclosure 

Communication on Progress (COP) by the United Nations Global 

Compact 

Countrylevel company form of the Extractive Industries Transparency 

Initiative (EITI) 

Submission of a tailored survey 

Other reporting framework by an industry or association please specify: 

None of the above 

Q 56 To what extent did you or your third party agents seek information from companies regarding their 

practices related to norms, standards, codes of conduct or international initiatives/ declarations/ 

conventions related to ESG issues in 2010 




Large 



any significant activities relating to Principle 3 that are not already captured by your answers above. 

1. Corporate Governance and Corporate Responsibility Voting Policy 

It has been Aviva Investors policy since 2001 to promote increased Corporate Responsibility (CR) reporting via its AGM voting. 

Where companies have declined to publish material information on their performance in this area, it has voted against or 

abstained on that company's annual report and accounts. In 2010, we voted at the AGMs of 604 companies on CR issues, 

which included 55 'Abstain' or 'Against' votes. In addition, Aviva Investors voted on 159 US shareholder resolutions relating to 

corporate responsibility issues including social, environmental and ethical (SEE) considerations. We voted in favour of 145 

(91%) of these resolutions. 

While our level of withholds demonstrates that the policy was applied robustly, overall voting levels do not give much insight into 

how effective these votes were at generating the change that they sought. One way of assessing this effectiveness is to look 

over time to see whether the company responded to the abstention or vote against. 

Clearly there can be a range of reasons for voting support from Aviva improving in this way. Nevertheless, when compared to the 

66 withholds (i.e. abstentions and votes against) in the 2009 data set there were 41 direct improvers in 2010. Improvers in this 

case are defined as a move from a vote against or abstention to support, or a vote against to abstain. Closer examination of 

specific cases suggests that the voting action and associated engagement may have been at least partly responsible for the 

improvement in corporate disclosure. 

2. UN Global Compact Engagement Programme 

Separate to this voting action, we also led a collaborative engagement programme aimed at signatories to the UN Global 

Compact. We welcomed good practice in their ESG communication on progress (COP) and challenged non conformance. The 

first phase of this initiative in 2008 involved us developing a coalition of twenty investors representing over US $2 trillion in 

assets. In Phase 1, we wrote to the chief executive officers of 103 companies in more than 30 different countries 25 

companies received the group's congratulations. In that programme, 20% of the companies that we asked to reengage with the 

Compact then did so, which we decided made the initiative worth repeating. 

We launched Phase 2 of this programme in 2009 and amassed more support with over thirty institutional investors representing 

over $3 trillion under management supporting us. In Phase 2, we wrote to 130 companies, with 25 of these receiving the group's 

congratulations for producing an excellent report. Of the 105 companies that we challenged to reengage with the Compact, 50 

(47.6%) are now active. The remaining 55 companies have been delisted (i.e. their membership has been cancelled) by the 

Global Compact. 

Due to the success of this engagement programme we launched Phase 3 in 2010. In Phase 3, we wrote to 130 companies, 

with 44 of these identified as leaders receiving the group's congratulations for producing an excellent report and 86 companies 

identified as laggards, 19 of which were exempted in early 2010 due to a moratorium for nonOECD/G20 companies enacted by 

the UN Global Compact. 27 out of 86 laggards regained active status by submitting a COP, while an additional 19 regained 

active status due to the moratorium. 30 laggards were delisted. 

We will be continuing the programme in 2011. 

3. Sustainable Stock Exchange initiative 

In November 2008 Aviva Investors' chief executive, Alain Dromer, called for all the listing authorities of the global stock markets 

to: (1) Consider updating their listing rules to include a provision that promotes disclosure of data on companies' sustainability 

performance and strategy, and (2) Make it a listing requirement that companies put a forwardlooking sustainability report and 

strategy to the vote at their AGMs. 

The UN Global Compact approached Aviva and proposed that the United Nations host an event on sustainable stock markets. 

On 2 November 2009, more than 100 top executives from around the world met at the UN headquarters in New York. There, 

they explored how the world's exchanges can work together with investors, regulators and companies to improve corporate 

transparency and performance on ESG issues, and encourage responsible longterm approaches to investment. This event was 

cohosted by the UNPRI, UN Global Compact and UNCTAD. The agenda examined the various ways in which stock exchanges 

can promote sustainable business practices, such as through enhanced sustainability reporting requirements for listed 

companies and the establishment of ESG indexes. 

In 2010 Aviva Investors designed, sponsored and set the agenda for a 'Call to Action' conference, held in September 2010 in 

Xiamen, China. This was a unique invitationonly event for heads of state, CEOs, company chairpersons, chief investment 

officers, senior members of government and top executives from worldwide stock exchanges. We continued to pursue our aim 

to promote a global listing environment that requires companies to consider how responsible and sustainable their business 

models are, and to encourage them to put a forwardlooking sustainability strategy to the vote at their AGMs. We also engaged 

with a number of stock exchanges individually with some encouraging results, notably Singapore and Malaysia. 


Principle 4 We will promote acceptance and implementation of the Principles within the investment 

industry. 

Principle 4 is about promoting the acceptance and implementation of the Principles for Responsible Investment (PRI) among your 

clients, service providers, partners, brokers/dealers and other investment industry players. In addition, it is about working with 

governments, regulators and international bodies to address and define approaches relating to ESG issues. 



does your organisation promote the acceptance and implementation of the Principles within the 

investment industry 

Please describe how you support the incorporation of ESG factors in the investment industry via 

mandates, incentives, Request for Proposals (RfPs), policy discussions etc. Please, indicate how your 

organisation does this in relation to clients and/or beneficiaries, peers or other entities. 




We promote acceptance of the PRI in three main ways: 

(1) Our awardwinning 'Investment Tutor' is a free training resource for pension fund trustees, including taught courses that we 

fund. The course includes a module on ESG which states: 

"Aviva Investors is a member of the UNPRI. We highly recommend that pension schemes consider becoming a signatory to the 

UNPRI, because the initiative seeks to keep its membership well informed and at the forefront of the various fascinating debates 

on sustainable and responsible investing." 

(2) Our client contracts commit us to sharing the results of the PRI assessment of our performance with clients. We believe this 

level of transparency will help them to hold us to account for being responsible investors, at no additional cost. To our 

knowledge, we are the first investment manager in the world to do this. 

(3) In 2010, a number of Aviva employees spoke at global PRI promotional events to provide a case study of implementation. 


Q 59 Did you include RI/ESG considerations when working with service providers and/or external 

investment managers in 2010 (where applicable) 

Specifically when: 

a. searching for service providers or external managers; 

b. agreeing on service requirements; 

c. structuring incentive schemes. 

Service providers or 

external managers 

a. Searches b. Agreements c. Incentives 

If you work with this type of service provider, 

please select "Yes, for all", "Yes, for some" or "No" 

We do not work 

with this type of 

provider 

Brokers / dealers Yes, for some Yes, for some Yes, for some 

External engagement 

service provider 

Investment consultant 

Investment research 

provider 

Proxy voting service 

provider 

Yes, for some Yes, for some Yes, for some 

Yes, for all Yes, for all Yes, for all 


Q 60 To what extent did you encourage peer organisations and/or your institutional clients and/or other 

investment industry players to consider RI/ESG issues in 2010 




Large 

Q 61 Does your broker evaluation process (which determines how you allocate commissions to brokers) 

include an ESG component, and/or do you have a budget to pay for broker research on ESG issues 


"Yes" or "No" 


Yes 

Q 62 To what extent do you identify ESG issues and suggest them to brokers or other investment 

research providers for research 




Large 

Q 63 To what extent did you engage in dialogue, lobbying or initiatives pertaining to government policy 

and/or industry regulations related to RI/ESG issues in 2010 




Large 




At Aviva Investors, we believe that the capital markets do not integrate sustainable development sufficiently to ensure that the 

cost to investors and society is minimised in the long run. We recognise that we can play an influential part in shaping 

government policy, and therefore continue to respond and offer opinion on policy developments in corporate performance and 

disclosure. 

Key public policy responses in 2010 include: 

1) Financial Reporting Council Stewardship Code we provided detailed feedback as part of the consultation and welcomed the 

Code when it was launched. 

2) UK Department for Business, Innovation and Skills: longterm focus consultation Aviva and Aviva Investors provided a joint 

submission to the Department for Business, Innovation and Skills (BIS) consultation on longterm focus. Our submission 

highlighted a number of observations by Aviva Investors of misaligned incentives throughout the supply chain which may require 

further analysis, as well as indicating areas of good practice or recent policies that should be kept under review. 

3) Operating and financial review in an open letter to the UK Government, Aviva Investors welcomed the commitment from the 

Coalition Agreement to reinstate an operating and financial review in corporate reporting. 

4) Climate change both Aviva and Aviva Investors signed an open letter to Vince Cable, the UK Government's business 

secretary, from the Aldersgate Group. It called in a strong and collective voice for the inclusion of mandatory reporting in the 

government's review, due by December 2011. 

We believe improving the way capital markets operate is one of the most fundamental responsibilities of responsible investors. 

. 


Principle 5 We will work together to enhance our effectiveness in implementing the Principles. 

Principle 5 is about collaborating with others in your implementation of responsible investment. The questions in this section are 

designed to capture the many ways in which signatories collaborate (for example by using the PRI Clearinghouse), and thus may 

overlap with areas discussed previously in the survey. However, the focus here is only those activities that involve working with 

others to implement the Principles. 



does your organisation work with other parties to enhance its implementation of the Principles 




We believe that investors have a collective interest in promoting high standards of corporate governance and corporate 

responsibility. In many cases, that collective interest is best promoted via collaborative engagement. We are a large and 

influential fund manager in our own right. Nevertheless, where we believe that it is more efficient and effective to collaborate, 

then we do so. In addition to collaborating via various institutions such as the SIFs, ICGN and the ABI, we have also signed up 

to numerous collaborative engagement initiatives on the PRI clearing house. 

Q 66 To what extent did you collaborate with other investors in regard to the Principles, and what 

Principle did you collaborate most on 

Extent of Collaboration 



Large 

Principle you collaborated most in 


Principle 1, 2, 3, 4 or 6 

Principle 3 

Q 67 Did you log in to the PRI Engagement Clearinghouse in 2010 and if so, how did you use it 

Logged in 

If Yes, please select all that apply 

Yes 

Led a collaborative engagement and posted it to the Clearinghouse 

Joined a collaborative engagement led by another signatory that 

was posted on the Clearinghouse 

Used it as a learning tool or keep up to date with current 

engagements 


Q 68 Did your organisation participate in any RI/ESGissue related associations 

Among those you did participate in, please select: 

the first, second and third most important to your organisation, and 

for the three most important, to what extent your organisation participated. 

For those not listed, please use the 'Other' field. 

Associations 

Please select 

all that apply 

Please select 

only one "Most important", 

one "Second most important" and 

one "Third most important" 

Only for these three 

most important, 

please select 

to what extent: 

"Large", 

"Moderate" or 

"Small" 

Association for Sustainable & 

Responsible Investment in Asia 

Carbon Disclosure Project (CDP) 

CFA Institute Centre for 

Financial Market Integrity 

Extractive Industries 

Transparency Initiative (EITI) 

GIGN Global Investors 

Governance Network 

Institutional Investors Group on 

Climate Change (IIGCC) 

Local Authority Pension Fund 

Forum 

Regional Social Investment 

Forums 

United Nations Environmental 

Program Finance Initiative 

(UNEP FI) 

Third most important 

Most important 

Second most important 

Large 

Large 

Moderate 



In addition to the work set out above, we also led a UN PRI Global Compact programme, where we collaborated with more than 

thirty other PRI investors (collectively representing c$2 trillion of assets under management) to target 130 companies (44 

leaders and 86 laggards, 19 of which were exempted in early 2010 due to a moratorium for nonOECD/G20 companies enacted 

by the UN Global Compact). At the end of 2010 27 out of 86 laggards regained active status by submitting a COP, while an 

additional 19 regained active status due to the moratorium and 30 laggards were delisted. 

We also worked with the UN PRI, UNCTAD and the Global Compact to design and fund a conference Xiamen, China on 

Sustainable Stock Exchanges. 


Principle 6 We will each report on our activities and progress towards implementing the Principles. 

Principle 6 is about your organisation's reporting of responsible investment activities (as opposed to Principle 3 which relates to 

the reporting of your investees or potential investees). The questions in this section focus on how you disclose your activities 

regarding the implementation of the Principles and where that disclosed information can be found. 


Q 70 Please provide a description of your organisation's approach to this Principle. For example, in what 

ways does your organisation report your implementation of the Principles Please include any sort of 

disclosure and transparency practices you have adopted. 




Transparency to our clients is a key element of our approach which we deliver via detailed quarterly reports on our use of their 

voting rights and, were appropriate, briefings on corporate engagement. We have also contractually undertaken to share the 

results of the PRI's assessment of our performance with our clients. More broadly, corporate governance policy and voting 

statistics are published on the Aviva Investors website, including our actual voting record on a company basis. We also include 

a report on our implementation of the Principles in the Aviva Investors regional report as part of the Aviva Group Corporate 

Responsibility report. 

We have also asked the PRI to publish our response to every questionnaire that we have submitted. 

It is important to note that to enable company consultations with shareholders to be frank and constructive, we treat these as 

client confidential. We generally avoid public comment about ongoing engagement. We have, however, made a number of 

exeptions (For example, where we wish to publicly welcome progress or coerce intransigent companies to respond.). 

Q 71 To what extent did you disclose, either to clients/beneficiaries or publicly, your policy and/or 

approach to incorporating ESG issues into investment analysis and decisionmaking processes in 2010 

Large 



If you disclosed, please indicate how this disclosure can be obtained a web address (URL) would be sufficient. If 

answering not at all, please explain why not. 

Yes, you did disclose: 

how can it be obtained 

Disclosed publicly at: 

http://www.avivainvestors.co.uk/about_us/our_corporate_governance/index.htm 

Detailed reports are client confidential. 

Did not disclose publicly: 

please explain why not 

Q 72 Did you disclose your voting policy in 2010 


Yes disclosed publicly 

If 'Yes, disclosed publicly', please indicate how it can be obtained a URL would be sufficient. If not, please explain 

why not. 

Yes, disclosed publicly: 






Q 73 Did you disclose your (proxy) voting record in 2010, and if so: 

How much of your voting record did you disclose 

Did you disclose the explanations/reasons for voting as you did 

How frequently did you disclose 

Did you disclose 

(please select one) 

How much of your 

voting 


How much 

explanation 


How frequently 

(please select any 

applicable) 

Yes disclosed 

publicly 

All votes 

No explanations 

votes 

Disclosed 

continuously (soon 

after votes are cast) 


why not. 






Q 74 Did you disclose your nonproxy voting active ownership and engagement policies or other 

documents that direct these activities 




why not. 






Q 75 To what extent did you disclose (either to clients/beneficiaries or publicly) your nonproxy voting 

RI/ESG issuerelated active ownership and engagement activities, results and progress in 2010 




Large 

If you disclosed, please indicate how this disclosure can be obtained a web address (URL) would be sufficient. If 

answering not at all, please explain why not. 

Yes, you did disclose: 


Please see link to the Aviva Investors regional report within the Aviva Group CR report 

http://www.aviva.com/reports/cr10/regions/avivainvestors/ 




Q 76 Did you disclose (either to clients/beneficiaries or publicly) RI/ESG activities, results and progress 

related to Principle 3, Principle 4 or Principle 5 in 2010 

Please select "Yes, disclosed publicly", "Yes disclosed to clients or beneficiaries only" or "Not at all" 

Principle 3 



why not. 







Principle 4 



why not. 



Please see here for link to investment tutor http://www.investmenttutor.com/ and the responsible 

investment modules http://www.investmenttutor.com/learning_topics/esg/xml_022444.html 




Principle 5 



why not. 





Please see link to our CR report which includes details of the Sustainable Stock Exchange initiative 

http://www.aviva.com/reports/cr10/regions/avivainvestors/trustintegrity/sustainablestockexchanges.html/ 



No additional comments.

Aviva Investors - Principles for Responsible Investment

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